Updated OFSI guidance on licenses for legal fees and expenses
The Office of Financial Sanctions Implementation (OFSI) recently updated section 3.4.1 of the Financial Sanctions Guidance.
The guidance now states that obtaining a license is encouraged rather than mandated before providing substantive legal services.
Obtaining a license in advance of providing services would create early certainty that 'reasonable' legal fees or expenses arising from the services could be recovered.
No payment by or on behalf of a designated person must be received in the absence of a licence from OFSI.